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One Freedom Valley Drive

Oaks, Pennsylvania 19456

October
2, 2025

VIA EDGAR AND EMAIL

U.S. Securities & Exchange Commission

Division of Investment Management

Office of Disclosure Review & Accounting

100 F Street, NE

Washington, D. C. 20549

Attention: Ms. Shandy Pumphrey

(202) 551-2393

pumphreys@sec.gov

 Re: The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File
No. 811-07102); &

The Advisors’ Inner Circle Fund III (File
No. 811-22920)

Ms. Pumphrey:

This letter responds to comments of the Securities
& Exchange Commission (the “SEC”) Staff given by you to me and other of my colleagues at SEI Investments Global Funds
Services (“SEI”), the Administrator to each of (a) The Advisors’ Inner Circle Fund (“AIC I”) (File No. 811-06400),
(b) The Advisors’ Inner Circle Fund II (“AIC II”) (File No. 811-07102), and (c) The Advisors’ Inner Circle Fund
III (“AIC III”) (File No. 811-22920) (AIC I, AIC II, and AIC III hereinafter referred to collectively as the “Trusts”),
in regard to certain series funds of the Trusts (each a “Fund,” and, collectively, the “Funds”) (the Trust and
the Funds, as appropriate, hereinafter also are referred to as the “Registrants”), in a telephone conversation on August 27,
2025. SEI provides the Trusts and the Funds with administrative and accounting services, officers, and other personnel, and submits these
responses on behalf of the Trusts and the Funds.

The SEC Staff comments provided relate to:

 a. the Trusts’ annual reports as of October 31, 2024, December 31, 2024, and March 31, 2025, as filed
on Form N-CSR (the “Form N-CSR Annual Reports”);

  The Advisors’ Inner Circle Fund (File No. 811-06400);

                         The Advisors’ Inner Circle Fund II (File No. 811-07102);
                         &

                         The Advisors’ Inner Circle Fund III (File No. 811-22920)

  October 2, 2025

 b. the Trusts’ semi-annual reports as of September 30, 2024, April 30, 2025, and June 30, 2025, as
filed on Form N-CSRS (the “Form N-CSRS Semi-Annual Reports”);

 c. the Trusts’ annual reports as of October 31, 2024, December 31, 2024, and March 31, 2025, as filed
on Form N-CEN (the “Form N-CEN Annual Reports”) (said Form N-CSR Annual Reports, Form N-CSRS Semi-Annual Reports, and Form
N-CEN Annual Reports hereinafter referred to collectively as the “Reports”);

 d. the corresponding Prospectuses of the certain Funds, as included in the Trusts’ Registration Statements
on Form N-1A; and

 e. related filings of the Trusts.

The SEC Staff comments provided specifically relate
to the Funds set forth immediately below, but these comments, to the extent applicable, should be applied to all Funds in the Trusts going
forward. As noted above, each of these Funds is a series of a Trust.

    The Advisors’ Inner Circle Fund I
    Cambiar Aggressive Value ETF

    The Advisors’ Inner Circle Fund II
    Kopernik Global All-Cap Fund

    The Advisors’ Inner Circle Fund II
    Kopernik International Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners Emerging Markets Equity Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners US Select Quality Value Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners Global Quality Equity Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners Global Quality Value Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners International Quality Value Fund

    The Advisors’ Inner Circle Fund III
    GQG Partners US Quality Value Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Core Bond Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Limited Duration Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Large Cap Growth Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Large Cap Value Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Small Cap Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus International Equity Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Real Estate Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus Long/Short Equity Fund

    The Advisors’ Inner Circle Fund III
    Knights of Columbus U.S. All Cap Index Fund

    The Advisors’ Inner Circle Fund III
    Strategas Global Policy Opportunities ETF

    The Advisors’ Inner Circle Fund III
    Strategas Macro Thematic Opportunities ETF

    The Advisors’ Inner Circle Fund III
    Strategas Macro Momentum ETF

    The Advisors’ Inner Circle Fund III
    FS Chiron Capital Allocation Fund

    The Advisors’ Inner Circle Fund III
    FS Chiron Real Development Fund

    The Advisors’ Inner Circle Fund III
    FS Multi-Strategy Alternatives Fund

    Page 2 of 13

©2025 SEI

    The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 October 2, 2025

We have reproduced the substance of your comments
below, followed by the Trusts’ corresponding responses.

*	*	*	*	*

SEC Comment 1:

Please explain why Item 5 in the most-recent Form
N-CSR Annual Reports and the most-recent Form N-CSRS Semi-Annual Reports was marked “Not Applicable” for each of the Cambiar
Aggressive Value ETF, the Strategas Global Policy Opportunities ETF, the Strategas Macro Thematic Opportunities ETF, and the Strategas
Macro Momentum ETF (collectively, the “ETFs”).

Trust Response to Comment 1:

Form N-CSRS Semi-Annual Reports do not
require a response to Item 5 pursuant to the Instruction in Form N-CSR, which states that the “information required by this Item
is only required in an annual report on this Form N-CSR.” Accordingly, Item 5 has been marked “Not Applicable” in previous
Form N-CSRS Semi-Annual Report filings.

The Registrant, on a going-forward basis,
shall provide an appropriate response to Item 5 in the Form N-CSR Annual Reports for each of the Cambiar Aggressive Value ETF, the Strategas
Global Policy Opportunities ETF, the Strategas Macro Thematic Opportunities ETF, and the Strategas Macro Momentum ETF (collectively, the
“ETFs”), as each of these four ETFs is a “listed” issuer, as that term is defined in Rule 10A-3(e)(9) under the
Securities Exchange Act of 1934, as amended.

*	*	*	*	*

SEC Comment 2:

Please confirm whether the Internal Control Report
(i.e., the Auditor Report) included in the December 31, 2024 Form N-CEN for the FS Multi-Strategy Alternatives Fund should make
reference to financial statements being consolidated [i.e., the financial statements for both (i) the FS Multi-Strategy Alternatives
Fund and (ii) the FS Alternatives Fund (Cayman), the FS Multi-Strategy Alternatives Fund’s wholly-owned subsidiary.

If these FS Multi-Strategy Alternatives Fund financial
statements do represent the consolidated financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives
Fund (Cayman), then please also confirm that, going forward, an appropriate note shall be provided in the Internal Control Report to be
included in the FS Multi-Strategy Alternatives Fund’s Form N-CEN that discloses that these financial statements represent the consolidated
financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman).

    Page 3 of 13

©2025 SEI

    The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 October 2, 2025

Trust Response to Comment 2:

Fund Management has confirmed with Ernst
& Young LLP, the Funds’ auditor, that the Internal Control Letter was intended to cover consolidated financial statements of
the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman).

Ernst & Young LLP has confirmed
that, going forward, the Internal Control Letter shall clearly disclose that the Internal Control Letter is intended to cover the consolidated
financial statements for both the FS Multi-Strategy Alternatives Fund and the FS Alternatives Fund (Cayman).

*	*	*	*	*

SEC Comment 3:

The responses for Item C.8.d. in the October 31,
2024 Form N-CEN for the Knights of Columbus Funds indicates that only the Knights of Columbus Large Cap Growth Fund, Knights of Columbus
Large Cap Value Fund, and Knights of Columbus Small Cap Fund recouped previously-waived expenses during the reporting period; whereas
the corresponding disclosure in the financial statements included in the October 31, 2024 Form N-CSR Annual Report for the Knights of
Columbus Funds indicates that only the Knights of Columbus Long/Short Equity Fund and Knights of Columbus International Equity Fund recouped
previously-waived expenses during this reporting period.

Accordingly, please reconcile these responses for
Item C.8.d. in the October 31, 2024 Form N-CEN for the Knights of Columbus Funds with the corresponding disclosure in the financial statements
that is included in the October 31, 2024 Form N-CSR Annual Report for the Knights of Columbus Funds.

Trust Response to Comment 3:

The Registrant confirms that Knights
of Columbus Asset Advisors LLC (“KOCAA”), the adviser of the Knights of Columbus Funds (the “KOC Funds”), recaptured
fees previously waived by KOCAA for each of the Columbus Long/Short Equity Fund and the Knights of Columbus International Equity Fund
for these KOC Funds’ during these KOC Funds’ fiscal-year-ended October 31, 2024. This is appropriately presented in the October
31, 2024 Form N-CSR Annual Report for the KOC Funds. The Funds’ October 31, 2024 Form N-CEN Annual Report for the KOC Funds incorrectly
disclosed that KOCAA did not recapture previously-waived fees for either the Columbus Long/Short Equity Fund or the Knights of Columbus
International Equity Fund during these KOC Funds’ fiscal-year-ended October 31, 2024.

    Page 4 of 13

©2025 SEI

    The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 October 2, 2025

The Registrant further confirms that,
for the KOC Funds’ fiscal-year-ended October 31, 2024, KOCAA did not recapture previously-waived fees for any of the Knights of
Columbus Large Cap Growth Fund, the Knights of Columbus Large Cap Value Fund, and the Knights of Columbus Small Cap Fund. This is appropriately
presented in the October 31, 2024 Form N-CSR Annual Report for the KOC Funds. The Funds’ October 31, 2024 Form N-CEN Annual Report
for the KOC Funds incorrectly disclosed that KOCAA recaptured previously-waived fees for each of the Knights of Columbus Large Cap Growth
Fund, the Knights of Columbus Large Cap Value Fund, and the Knights of Columbus Small Cap Fund during these KOC Funds’ fiscal-year-ended
October 31, 2024.

On a going-forward basis, the Registrant
shall review the KOC Funds’ Form N-CSR Annual Report and the KOC Funds’ Form N-CEN Annual Report so as to confirm that these
KOC Funds’ Reports are in alignment.

*	*	*	*	*

SEC Comment 4:

Each of the six GQG Partners Funds checked off
Item C.7.e in the GQG Partners Funds’ March 31, 2025 Form N-CEN so as to report that each said GQG Partners Fund relied on Rule
17a-7 under the Investment Company Act of 1940, as amended (the “1940 Act”) in regard to participating in “cross-trades”
during the reporting period. The financial statements for the six GQG Partners Funds that are included in the March 31, 2025 Form N-CSR
Annual Report, however, do not include any disclosure regarding these cross-trade activities for this reporting period.

Accordingly, please confirm whether any of the
six GQG Partners Funds participated in “cross-trades” during the fiscal-year-ended March 31, 2025 (i.e., please confirm
whether the six GQG Funds correctly answered Item C.7.e in the GQG Partners Funds’ March 31, 2025 Form N-CEN).

Trust Response to Comment 4:

The Registrant confirms that none of
the six GQG Partners Funds participated in cross-trading during the GQG Partners Funds’ fiscal-year-year ended March 31, 2025, and,
as such, none of the six GQG Partners Funds relied on Rule 17a-7 under the 1940 Act. The GQG Partners Funds’ March 31, 2025 Form
N-CSR Annual Report, which contains no additional disclosure for cross-trading activity by the six GQG Partners Funds, is accurately presented.

    Page 5 of 13

©2025 SEI

    The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 October 2, 2025

This is appropriately presented in the
March 31, 2024 Form N-CSR Annual Report for the GQG Partners Funds. The response to Item C.7.e in the GQG Partners Funds’ March
31, 2024 Form N-CEN Annual Report for the KOC Funds is incorrect and should not have indicated that the six GQG Partners Funds relied
on Rule 17a-7 under the 1940 Act during the GQG Partners Funds’ fiscal-year-year ended March 31, 2025.

On a going-forward basis, the Registrant
shall review the GQG Partners Funds’ Form N-CSR Annual Report and the GQG Partners Funds’ Form N-CEN Annual Report so as to
confirm that these GQG Partners Funds’ Reports are in alignment.

*	*	*	*	*

SEC Comment 5:

Each of the six GQG Partners Funds -- including
each of the GQG Partners Emerging Markets Equity Fund, the GQG Partners Global Quality Value Fund, and the GQG Partners International
Quality Value Fund -- has been identified at Item C.4 in the GQG Funds’ March 31, 2025 Form N-CEN Annual Report as being “non-diversified,”
as that term is defined at Section 5(b)(2) of the 1940 Act; however, each of the GQG Partners Emerging Markets Equity Fund, the GQG Partners
Global Quality Value Fund, and the GQG Partners International Quality Value Fund appears to be operating as a “diversified fund,”
as that term is defined at Section 5(b)(1) of the 1940 Act, based on the Top-Ten Holdings disclosures in the March 31, 2025 Annual (Tailored)
Shareholder Reports for these three GQG Partners Funds.

Note 1 to the financial statements that are included
in the GQG Partners Funds’ March 31, 2025 Form N-CSR Annual Report also discloses that each of the GQG Partners Funds is classified
as a “non-diversified fund,” as that term is defined at Section 5(b)(2) of the 1940 Act.

Accordingly: (i) please confirm whether each of
the GQG Partners Emerging Markets Equity Fund, the GQG Partners Global Quality Value Fund, and the GQG Partners International Quality
Value Fund continues to qualify as a “non-diversified” fund; and (ii) if any of these three GQG Partners Funds has been operating
as a “diversified fund” for more than three years, please confirm that, pursuant to Rule 13a-1 under the 1940 Act, that GQG
Partners Fund shall obtain the required shareholder approval to change that GQG Partners Fund’s diversification classification to
“non-diversified” prior to changing that GQG Partners Fund’s diversification classification back to “non-diversified.”

    Page 6 of 13

©2025 SEI

    The Advisors’ Inner Circle Fund (File No. 811-06400);

The Advisors’ Inner Circle Fund II (File No. 811-07102); &

The Advisors’ Inner Circle Fund III (File No. 811-22920)

 October 2, 2025

Trust Response to Comment 5:

The Registrant confirms that each of
the GQG Partners Emerging Markets Equity Fund, the GQG Partners Global Quality Value Fund, and the GQG Partners International Quality
Value Fund continues to qualify as a “non-diversified fund,” as that term is defined at Section 5(b)(2) of the 1940 Act.

While each of these three GQG Partners
Funds temporarily may not have qualified as a “non-diversified fund” as of the March 31, 2025 date of the Annual (Tailored)
Shareholder Report for these three GQG Partners Funds, each of these three GQG Partners Funds has continued to qualify as a “non-diversified
fund” during, albeit not continuously during